2
After concessions by the parties, the issues for decision
are:
(1) Whether petitioner had gross receipts during the
taxable year 1988 from a business known as Ticketline. We hold
that he did.
(2) Whether petitioner has substantiated cost of goods sold
for Ticketline for the taxable year 1988. We hold that
petitioner has substantiated cost of goods sold in the amount of
$143,004.
(3) Whether petitioner is liable for self-employment tax
for the taxable year 1988 from his activities with Ticketline.
We hold that he is.
(4) Whether the costs associated with petitioner's
nutritional information system are deductible pursuant to section
174. We hold that they are not.
(5) Whether petitioner is liable for the addition to tax
pursuant to section 6651(a)(1) for failure to file timely
Federal income tax returns for the taxable years 1988 and 1989.
We hold that he is.
(6) Whether petitioner is liable for the addition to tax
pursuant to section 6653(a)(1) for negligence for the taxable
year 1988. We hold that he is.
(7) Whether petitioner is liable for the addition to tax
pursuant to section 6661 for a substantial understatement of tax
for the taxable year 1988. We hold that he is.
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